FPL Group, Inc. and Subsidiaries v. Commissioner

116 T.C. No. 7

UNITED STATES TAX COURT FPL GROUP, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 5271-96. Filed February 1, 2001. On its consolidated Federal income tax returns for the years in issue, F claimed a credit for Federal taxes on fuels. F now seeks credits in addition to amounts claimed on F’s original Federal income tax returns. R argues that the so-called “one claim” rule contained in sec. 6427(i)(1), I.R.C., acts as a bar to F’s additional claims for credit under sec. 34, I.R.C. Held: F is not barred by the so-called “one claim” rule…